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CA & VA Notice of Collection & Privacy Policy

Effective Date: January 1, 2023

Last Reviewed/Revised on: May 11, 2023

Notice at Collection and Privacy Policy for California and Virginia

This California and Virginia Notice at Collection and Privacy Policy (“State Privacy Disclosure”) explains how Citi Trends, Inc. and its subsidiaries and affiliates (“Company”, “us”, “our”, or “we”) collect, use, disclose, sell, share, and/or retain personal information (“Information Practices”) subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). This State Privacy Disclosure applies solely to California and Virginia residents (“consumers” or “you”).

This State Privacy Disclosure does not apply to information we collect in the context of a California resident’s interaction with us as a job applicant, employee, contractor, or other role within our Company. Please refer to our Workforce CCPA Disclosure.

The terms used in this State Privacy Disclosure shall have the same or similar meaning as those terms in each of the CCPA and VCDPA, or the closest approximation of such term, as defined in each statute.

Notice at Collection

The following notice identifies the categories of personal information or personal data (collectively, “personal information”) to be collected from you and the purposes for which the personal information will be used, including whether that information is sold to anyone or shared with third parties who are not our vendors or service providers (“Non-Service Providers”).

General Personal Information

Categories of Personal Information

Purposes for Collection and Use

Sold or Shared with Non-Service Providers

Identifiers: For example, a name, address, online identifier, Internet Protocol address, email address, or other similar identifiers.

  • To fulfill or meet the reason for which the information is provided or for our internal operation purposes (such as servicing transactions and accounts and providing services on behalf of the business)

  • Fraud and security detection, debugging, or short-term data use for the current transaction

  • To facilitate financial incentives, such as sweepstakes and other promotions, when you provide your information.

  • Verify, maintain, or improve the quality or safety of the services and products we provide.

  • To share the personal information with service providers to carry out other business purposes.

Yes, with lead generators and Non-Service Provider adtech trackers on our website.

(California Residents Only) Personal Information Categories from Cal. Civ. Code § 1798.80(e): For example, a name, signature, physical characteristics or description, address, telephone number, or financial information.

  • To fulfill or meet the reason for which the information is provided or for our internal operation purposes (such as servicing transactions and accounts and providing services on behalf of the business)

  • Fraud and security detection, debugging, or short-term data use for the current transaction

  • To facilitate financial incentives, such as sweepstakes and other promotions, when you provide your information.

  • Verify, maintain, or improve the quality or safety of the services and products we provide.

  • To share the personal information with service providers to carry out other business purposes.

No

(California Residents Only) Characteristics of CA or Federal Protected Classifications: For example, age (40 and over), gender, and ethnicity.

  • This information may be collected from you through voluntary surveys. You are not required to provide us with this information. We use this information to improve our product selection and customer service.

No

Commercial Information: For example, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • To fulfill or meet the reason for which the information is provided or for our internal operation purposes (such as servicing transactions and accounts and providing services on behalf of the business)

  • Verify, maintain, or improve the quality or safety of the services and products we provide.

  • To share the personal information with service providers to carry out other business purposes.

No

Internet or Other Similar Network Activity: For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

  • Fraud and security detection, debugging, or short-term data use for the current transaction

  • For internet marketing (including targeted advertising) and website analytics.

Yes, with Non-Service Provider adtech trackers on our website.

Sensory or Surveillance Data: For example, security footage.

  • Fraud and security detection, debugging, or short-term data use for the current transaction

No

Profile Data: For example, inferences drawn from personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes.

  • Verify, maintain, or improve the quality or safety of the services and products we provide

  • For internal analytics, research and marketing and to understand our customer base.

No



We do not collect: biometric information, geolocation data, professional or employment related information, or education information under this policy.

Sensitive Personal Information

In certain instances, you are provided the opportunity to disclose your race or ethnicity to us. This information may be collected from you through voluntary surveys and with your consent. You are not required to provide us with this information. We use this information to improve our customer service.

You may withdraw your consent or limit our use by contacting us at privacy@cititrends.com or (844) 968-1067.

We do not collect: Social Security number, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number when provided with any required security or access code, password, or credentials allowing access to an account; religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages (unless we are the intended recipient of the communication); genetic data; biometric information for the purpose of unique identification; health information; information concerning sex life or sexual orientation; precise geolocation.

Retention Periods

We retain information for different periods of time depending on the purposes for which we collect and use it. We will delete or de-identify information when it is no longer needed to fulfill the purposes listed for each category above, unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information.

Notice of Sale and/or Share

Our use of tracking technologies may be considered a sale or sharing with Non-Service Providers under California or Virginia law. You can opt-out of such sale or being tracked by these Non-Service Providers by clicking the “Your Privacy Choices” link at the bottom of our website.



Please see our California and Virginia Privacy Policy immediately below for additional information on our Information Practices.





Privacy Policy

The purpose of this privacy policy is to provide you with a comprehensive description of our online and offline practices regarding our Information Practices. You have certain rights to control the use of your personal information. This privacy policy describes your rights as it relates to our Information Practices as to your personal information and how you can exercise those rights.

The following table includes disclosures for the preceding 12 months of: categories of personal information we have collected about consumers, the categories we have disclosed for a business purpose, and categories of third parties with whom we disclosed the personal information during that period.

General Personal Information

Category

In the preceding 12 months this category was:

Business or Commercial Purpose for Collection & Disclosure

Categories of third parties to whom the information was disclosed

Collected

Disclosed

Identifiers

  • To provide our products and services to you. For example, to facilitate a sale of our products

  • To combat fraud and loss and to protect the physical safety of our customers, employees, and patrons

  • To provide you with promotions, coupons, and other incentives on our products

  • To perform quality assurance and control for our business and to protect the integrity and security of our systems

  • To carry out other business purposes, including engaging vendors and service providers to provide additional services necessary for our business functions

  • Transactional service providers such as payment processors

  • Operational service providers such as financial accounting, internet service, cloud storage, web hosting, or email distribution providers

  • Analytics and research service providers such as data analytics providers

  • Pursuant to legal process or with government entities

  • Social networks

  • Customer Service or Help Desk service providers

  • Security and Cybersecurity service providers

  • Lead generation third parties

  • Advertising networks

(California Residents Only)

Personal Information Categories from Cal. Civ. Code § 1798.80(e)

  • To provide our products and services to you. For example, to facilitate a sale of our products

  • To combat fraud and loss and to protect the physical safety of our customers, employees, and patrons

  • To provide you with promotions, coupons, and other incentives on our products

  • To perform quality assurance and control for our business and to protect the integrity and security of our systems

  • To carry out other business purposes, including engaging vendors and service providers to provide additional services necessary for our business functions

  • Transactional service providers such as payment processors

  • Operational service providers such as financial accounting, internet service, cloud storage, web hosting, or email distribution providers

  • Analytics and research service providers such as data analytics providers

  • Pursuant to legal process or with government entities

  • Social networks

  • Customer Service or Help Desk service providers

  • Security and Cybersecurity service providers

  • Lead generation third parties

(California Residents Only)

Characteristics of CA or Federal Protected Classifications

This information may be collected from you through voluntary surveys. You are not required to provide us with this information. We use this information to improve our customer service.

  • None

Commercial Information

  • To provide our products and services to you. For example, to facilitate a sale of our products

  • Verify, maintain, or improve the quality or safety of the services and products we provide.

  • To share the personal information with service providers to carry out other business purposes.

  • Transactional service providers such as payment processors

  • Operational service providers such as financial accounting, internet service, cloud storage, web hosting, or email distribution providers

  • Analytics and research service providers such as data analytics providers

  • Customer Service or Help Desk service providers

Internet or Other Similar Network Activity

  • Fraud and security detection, debugging, or short-term data use for the current transaction

  • For internet marketing (including targeted advertising) and website analytics.

  • Security and Cybersecurity service providers

  • Advertising networks

Sensory or Surveillance Data

  • Fraud and security detection, debugging, or short-term data use for the current transaction

 

  • Loss prevention and store monitoring

  • Security and Cybersecurity service providers

  • Pursuant to legal process or with government entities

Profile Data

  • Verify, maintain, or improve the quality or safety of the services and products we provide

  • For internal analytics, research and marketing and to understand our customer base.

  • None



We do not collect: biometric information, geolocation data, professional or employment related information, or education information under this policy.

Sensitive Personal Information

In certain instances, you are provided the opportunity to disclose your race or ethnicity to us. This information may be collected from you through voluntary surveys and with your consent. You are not required to provide us with this information. We use this information to improve our customer service.

You may withdraw your consent or limit our use by contacting us at privacy@cititrends.com or (844) 968-1067.

We use or disclose sensitive personal information for the business purposes listed below. See the below section on how you can limit certain uses and disclosures of sensitive personal information.

Category

In the preceding 12 months this category was:

Business or Commercial Purpose for Collection & Disclosure

Categories of third parties to whom the information was disclosed

Collected

Disclosed

Race or Ethnicity

  • To improve our product selection and customer service through surveys.

None



We do not collect: Social Security number, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number when provided with any required security or access code, password, or credentials allowing access to an account; religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages (unless we are the intended recipient of the communication); genetic data; biometric information for the purpose of unique identification; health information; information concerning sex life or sexual orientation; precise geolocation.

The categories identified as collected in the tables above were collected from the following categories of sources:

  • You directly

  • Advertising networks

  • Internet service providers

  • Data analytics providers

  • Government entities

  • Operating systems and platforms

  • Social networks

What We Sell to or Share with Non-Service Providers and Right to Opt-Out

We have sold to or shared with Non-Service Providers personal information in the preceding 12 months as disclosed in the table below.

General Personal Information

Categories sold to or shared with Non-Service Providers over the last 12 months

Categories of Non-Service Providers to whom this category of personal information has been sold or shared

Identifiers

  • Lead generating providers

  • Advertising networks

  • Data analytics providers

Internet or Other Similar Network Activity

  • Lead generating providers

  • Advertising networks

  • Data analytics providers



We have not sold or shared with Non-Service Providers sensitive personal information in the preceding 12 months.

The purpose of the notice of Right to Opt-Out is to inform you that you have the right to direct us to stop selling or sharing your personal information, which is called the “Right to Opt-Out.”

You may exercise your Right to Opt-Out by: (1) Clicking “Your Privacy Choices”, or (2) contacting us at privacy@cititrends.com or (844) 968-1067.

Once you make an opt-out request, we will comply within 15 business days. We will wait at least twelve (12) months before asking you to reauthorize personal information sales or sharing.

We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

Your Right to Know

You have the right to request that we disclose any of the following:

  • the categories of personal information we have collected about you

  • the categories of sources from which the personal information is collected

  • the business or commercial purpose for collecting, selling, or sharing with third parties or Non-Service Providers

  • the categories of third parties and Non-Service Providers to whom we disclose personal information

  • the specific pieces of personal information we have collected about you

You can do this through a verified consumer request. That process is described below in the section, “How to Exercise Your Rights.”



Your Right to Request Correction of Inaccurate Personal Information

You have the right to request correction of inaccurate personal information maintained by us. We may request documentation from you to determine the accuracy of the information. If you provide us documentation either upon our request or through your own initiative, that documentation will only be used for the purpose of correcting your personal information and complying with our recordkeeping requirements. We may deny your request if we have previously denied your same request to correct an alleged inaccuracy in the past six (6) months, unless you provide new or additional documentation that the information at issue is inaccurate.

As an alternative to correction, we may delete the inaccurate information if it does not negatively impact you or if you consent to this deletion. We reserve the right to deny this request if allowed under law, or if we determine that the contested information is more likely than not accurate, based on the totality of circumstances. You can submit a correction request through a verified consumer request. That process is described below in the section, “How to Exercise Your Rights.”

Your Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to limit our use and disclosure of your sensitive personal information collected by us, which is called the “Right to Limit.” You do not have the right to limit certain uses and disclosures of your sensitive personal information for the following purposes:

  • Providing our goods or services reasonably expected of an average consumer;

  • Detecting security incidents affecting personal information, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose;

  • Resisting malicious, fraudulent, or illegal actions against us and prosecuting persons responsible for such actions, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose;

  • Ensuring the physical safety of an individual, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose;

  • Short-term, transient use, including non-personalized advertising shown as part of a consumer’s current interaction with us, provided that we do not build a profile about the consumer or alter the consumer’s experience outside their current interaction with us;

  • Performing services on behalf of another business (e.g., maintaining accounts, processing orders or transaction);

  • Verifying or maintaining the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, or improving, upgrading, or enhancing the services or device owned, manufactured, manufactured for, or controlled by us; or

  • To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.



Right to Limit: You may withdraw your consent or limit our use of your race or ethnic origin by contacting us at privacy@cititrends.com or (844) 968-1067.

Once you make a request to limit, we will comply within 15 business days. We will wait at least twelve (12) months before asking you to reauthorize the use or disclosure of your sensitive personal information beyond the limited purposes specified above.

Your Right to Request Deletion of Your Personal Information

You have the right to request that we delete any of your personal information collected by us, subject to certain exceptions. You can do this through a verified consumer request. That process is described below in the section, “How to Exercise Your Rights.”

There may be scenarios where we deny your deletion request. If that occurs, we will provide you with an explanation as to why we could not delete all or some of your personal information.

How to Exercise Your Rights

You have the right to exercise your rights and submit verified consumer requests to know information (and to receive your personal information in a portable format), to correct information, or for deletion.

The response to a request to know will provide all personal information collected and maintained about you since January 1, 2022, in a portable format, unless doing so proves impossible or would involve disproportionate effort. Please note that we are not required to provide personal information to you more than twice in a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

You can submit requests by contacting us at privacy@cititrends.com or (844) 968-1067. Your request will be verified using the information you provide. If you email us or call us at (844) 968-1067, you must provide your full name and the email address you provided to the Company. Your request will be verified by matching the information you provide to us with information that we have collected about you.

If you submit a request that is not through one of these designated methods or is deficient in some manner unrelated to verification, we will provide you with information on how to submit the request or remedy any deficiencies.

Once we receive your verifiable consumer request, we will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 calendar days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.

Requests to Know or Delete for Child Under the Age of 13: We do not knowingly collect information of minors under the age of 13.



Other California Privacy Rights

California’s “Shine the Light” law (Civil Code § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@cititrends.com or write us at: Citi Trends, Inc., 104 Coleman Boulevard, Savannah, GA 31408.

Company responds to Do Not Sell or Share Opt-Out requests as disclosed in the section “What We Sell to or Share with Non-Service Providers and Right to Opt-Out.” Other parties may collect personally identifiable information about your activities over time and across different Web sites when a consumer uses our Web site or service.

Using an Authorized Agent to Submit a Request

Only you, or a natural person or a business entity registered with the Secretary of State to conduct business in California that you have authorized to act on your behalf, may make a verifiable consumer request related to your personal information or a request to opt-out. You may also make a verifiable consumer request or a request to opt-out on behalf of your minor child. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to provide the authorized agent signed permission to submit a request, verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request. When submitting a request on behalf of a consumer, please provide the necessary information so we may be able to confirm that you are an authorized agent.

Your Right to Non-Discrimination for the Exercise of a Privacy Right

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may still offer you certain financial incentives permitted by the CCPA such as discounts, rewards, premium features, loyalty accounts, or club card programs that can result in different prices, rates, or quality levels.

Notice of Financial Incentive

The purpose of this notice of financial incentive is to explain to you the material terms of a financial incentive we are offering so that you may make an informed decision on whether to participate.

We currently provide the following financial incentives:

Name of Service with Financial Incentive

Customer survey sweepstakes (“Giveaway”)

Sign-Up For Text Promotions (“Text Promotions”)

Categories of Information

Identifiers: Name, e-mail address and phone number (required).

Other information: Age, gender and ethnicity (optional).

Identifier: Phone number (required), email address (optional).

Summary of Financial Incentive

This financial incentive provides an opportunity to win a prize, such as a $100 gift card for providing information in response to an online survey.

When you sign up using your phone number to receive messages, we will provide you certain discounts on items, such as a coupon for $5 off for every $50 you spend with us. Each promotion is different.

Description of the Terms of the Financial Incentive If Applicable

The full terms of the customer survey sweepstakes, Giveaway, are found here: https://cititrends.com/csat-sweepstakes-official-rules/

 

Please see our Terms and Conditions to learn about the rules of our Text Promotions.

Explanation of how the financial incentive or price or service difference is reasonably related to the value of the consumer’s data

In our good-faith estimation the value of the financial incentive offer reflects the value Citi Trends receives from obtaining the customer’s information provided in response to the survey. The incentive may fluctuate based on a number of variables such as the time of year, upcoming holidays, and the response to the survey.

In our good-faith estimation the value of the financial incentive offer reflects the value Citi Trends receives from obtaining the customer’s information provided when a consumer signs up for Text Promotions, such as the number of coupons consumers use over a certain time period.

How to Opt-In

After you click on the link above to get to the full terms of the Giveaway, scroll to the section “HOW TO ENTER, DRAWINGS, and PRIZES/ODDS” to learn how to enter into the Giveaway.

Provide your phone number at the bottom of our website.

How to Opt-Out of the Giveaway

Consumers have the right to withdraw from the any of our Giveaway at any time. Consumers may exercise that right by contacting us at privacy@cititrends.com or (844) 968-1067.

Follow the instructions when you receive text messages from us.





Other Virginia Privacy Rights

Right to Appeal

As a Virginia resident, you have the right to appeal our refusal to take action on, or respond to, a verified consumer request. Upon receipt of our denial or refusal to take action on, or to respond to, a verified consumer request, a Virginia resident has 60 days to submit a request to appeal our decision by contacting us at privacy@cititrends.com. Within 60 days of the receipt of your appeal request, we will inform you in writing of any action taken or not taken in response. We will also include a written explanation of the reasons for our decision. If your appeal is denied, you have the right to contact the Virginia Attorney General at (804) 786-2071.

Right to Opt-Out of Certain Profiling

You have the right to opt-out of our use of profiling when used to make decisions that produce a legal or similarly significant effect concerning you or your interactions with us. Currently, Company does not engage in such profiling.





Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact for More Information

If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (844) 968-1067

Email: privacy@cititrends.com

Postal Address: Citi Trends, Inc., 104 Coleman Boulevard, Savannah, GA 31408

Attn: Privacy